CMS Releases New RHC Fact Sheet
Clarifies G0511 Add-On Code Policy
CMS recently released an updated MLN06398, Information for Rural Health Clinics, updating several sections of the fact sheet to reflect policies finalized in 2024 rules.
Most notably, this document provides some additional clarification on how care management services can be billed with multiple G0511 codes per claim.
CMS provides a table of codes that can be billed as G0511, so long as all requirements are met and that resource costs are not double counted. Addressing a question that the NARHC community was specifically awaiting clarification on, they also clarify that the table “does not include add-on code pairs or codes that describe additional minutes.”
In future comment periods, NARHC will advocate to CMS that RHCs should have opportunities to bill for ALL care management services they provide to patients, including for additional time-based increments, just as Medicare fee-for-service providers are eligible to bill for these add-on services.
Additionally, CMS provided details on the Social Determinants of Health (SDOH) risk assessment code (G0136), newly billable this year. While this is not a separately reimbursable code in the RHC setting, when the risk assessment is performed as part of an Annual Wellness Visit (AWV), patient cost sharing is waived. Cost sharing would apply if the risk assessment was performed with another qualifying visit, such as an E/M. The risk assessment can be performed no more often than once every 6 months.
Finally, please note that on page 8 CMS states “For most other services, Part B deductible and coinsurance rates apply, which means once patients meet their Part B deductible, we pay 80% of the AIR and the patient pays the remaining 20%.” This should read “we pay80% of the AIR and the patient pays 20% of the total charges. ”NARHC has contacted the CMS payment team for this to be fixed.
Please contact Sarah.Hohman@narhc.org with any questions.
Sincerely,
The National Association of Rural Health Clinics
